DOJ “Tweaks” FCPA Corporate Enforcement Policy
The Justice Department is wedded to its FCPA Corporate Enforcement Policy (excuse me for the use of “wedded,” we recently celebrated our son’s wedding). Nonetheless, DOJ has to adjust its Policy in response to experience and feedback. That is a good thing and one that helps to ensure that the Policy is predictable and consistent in its application. I am convinced that the FCPA Corporate...